March 23, 2013

HAVING A FOREIGN BANK ACCOUNT IS NOT A CRIME. YET. Government Loses First Offshore Bank Account Prosecution. “[T]he Government rarely loses criminal tax prosecutions. This is believed to be the first unsuccessful prosecution relating to the use of foreign bank accounts in the Government’s ongoing international enforcement efforts. The Government must objectively and carefully select the cases to prosecute — the mere presence of a foreign bank account and foreign trust does [not] mean there has been a tax crime — an assumption which seemed to blindly guide the prosecution of Mr. Pflueger, an innocent man.”